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TTI, Inc.

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Released: July 31, 2013

Federal Communications Commission

DA 13-1671

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of

TTI, Inc.
Facility I.D. No. 30283
Licensee of Station WJMY-CA
NAL/Acct. No.: 201341420013
Demopolis, Alabama
FRN: 0005016720


Adopted: July 30, 2013

Released: July 31, 2013

By the Chief, Video Division, Media Bureau:



The Video Division issued a Notice of Apparent Liability for Forfeiture ("NAL") to TTI,
Inc. ("Licensee") based on its apparent violation of Section 73.3526(e)(11)(iii) of the Rules by failing to
file timely with the Commission the Children's Television Programming Reports for Station WJMY-CA.1
Based upon our review of the Licensee's response and the facts and circumstances surrounding it, we
hereby rescind the NAL and cancel the proposed forfeiture.



The NAL proposed a forfeiture of $3,000 based on the Licensee's failure to file its
Children's Television Programming Reports in a timely manner during seven quarters of the license
period.2 The NAL noted that four of the reports were filed within five days after the quarterly deadline
and that we would be inclined to dismiss those late filings as de minimis absent the additional late filings.
Commission records showed that three of the reports were filed more than 30 days after the filing
Licensee filed a timely response on June 11, 2013.4 In that response, the Licensee stated
that two of the three reports in question were filed on or close to the filing deadline but appeared to be late
due to the Licensee's misdating of one of the reports. That misdating of the report caused the filing
system to read the reports as untimely. The Licensee stated that it became aware of the filing problem
and attached a note of correction to the re-filed report.5 The Licensee attached copies of the reports in
support of its contentions.



4. The Licensee's showing demonstrates that two of three reports that appeared to be filed more

1 TTI, Inc., Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 7444 (Vid. Div. 2013).
2 Id.
3 Id. at 7444 n.4.
4 Licensee Response to Notice of Apparent Liability ("Licensee Response") (Jun. 11, 2013).
5 Id. at 2-3.

Federal Communications Commission

DA 13-1671

than 30 days late were in fact filed on or close to the filing deadline.6 Based on the Licensee's showing,
we believe the remaining late filings are de minimis in nature and the proposed NAL should be rescinded
and the forfeiture cancelled.



Accordingly, IT IS ORDERED that the Notice of Apparent Liability for Forfeiture issued
to TTI, Inc. is hereby RESCINDED and the proposed $3,000 forfeiture is CANCELLED.
IT IS FURTHER ORDERED that copies of this Order shall be sent, by First Class and
Certified Mail, Return Receipt Requested, to TTI, Inc., Post Office Box 70937, 5455 Jug Factory Road,
Tuscaloosa, Alabama, 35407, and to its counsel, M. Scott Johnson, Esq., Fletcher, Heald & Hildreth,
P.L.C., 1300 N. 17th Street, 11th Floor, Arlington, Virginia, 22209.
Barbara A. Kreisman
Chief, Video Division
Media Bureau

6 The third untimely report was for the first quarter of 2007. System problems prevented many licensees from
making timely filings that quarter, and we have therefore decided to remove that quarter from our review of licensee
compliance with Children's Television Programming report filing deadlines.

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